Case Digest (G.R. No. 97898) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Gloria A. Chico v. Elsie Ciudadano (G.R. No. 249815, July 4, 2022), petitioner Gloria A. Chico bought at a July 8, 2010 tax delinquency sale a parcel of land originally titled in the name of Rosalita G. Bengzon under Transfer Certificate of Title (TCT) No. 57394 (PR-11986). Upon expiry of the one-year redemption period, the Quezon City Treasurer issued a Final Bill of Sale conveying the property to Chico. On April 10, 2012, Chico filed in the Regional Trial Court (RTC), Branch 83, Quezon City, LRC Case No. Q-33350(12), a Petition for Issuance of a New Title under Sections 75 and 107 of Presidential Decree No. 1529, praying for cancellation of TCT No. 57394 and issuance of a new title in her name. Notices were sent to the Office of the Solicitor General, Land Registration Authority, Register of Deeds of Quezon City, and others, and posted in public places; no opposition was filed. The RTC granted Chico’s petition by Decision dated December 10, 2012, and its Amended Decision of Case Digest (G.R. No. 97898) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- April 10, 2012 – Petitioner Gloria A. Chico filed a Petition for Issuance of a New Title under P.D. No. 1529, §§ 75 & 107, alleging she was the highest bidder in the July 8, 2010 tax delinquency sale of the land covered by TCT No. 57394 (PR-11986) registered in the name of Rosalita G. Bengzon. She claimed the one-year redemption period lapsed and attached thereto copies of:
- TCT No. 57394 (PR-11986) and tax declaration;
- Warrant and notice of levy;
- July 30, 2010 Certificate of Sale;
- January 12, 2012 Final Bill of Sale;
- Property identification map.
- Notices of hearing were served on Chico, her counsel, the OSG, LRA, RD-Quezon City, City Prosecutor and City Attorney, and posted publicly.
- RTC proceedings and decisions
- May 24, 2012 – RTC Branch 83 declared general default; no opposition filed.
- December 10, 2012 Decision – RTC granted the petition, ordered cancellation of TCT No. 57394 (PR-11986), issuance of new TCT to Chico and issuance of a writ of possession to eject occupants. RD-QC cancelled the old title and issued TCT No. 004-2016005243 in Chico’s name.
- June 27, 2013 Amended Decision – corrected title number to “57394 (PR-11986).” Certificate of finality issued April 7, 2015. Chico pursued writ of possession (LRC Case No. R-QZN-16-08936-LR).
- Petition for Annulment of Judgment before the CA
- January 16, 2017 – Respondent Elsie Ciudadano filed a petition under Rule 47, alleging she bought the property by a June 23, 1989 Deed of Absolute Sale (annotated on TCT No. 57394 in June 1989), has possessed it since 1992, and was never impleaded nor served notice in the issuance-of-new-title case. She invoked extrinsic fraud and lack of jurisdiction.
- April 5, 2019 CA Decision – granted annulment petition, set aside the RTC’s December 2012 and June 2013 decisions, declared Chico’s TCT No. 004-2016005243 void, and reinstated TCT No. 57394 (PR-11986) in Bengzon’s name.
- October 8, 2019 Resolution – denied Chico’s motion for reconsideration.
Issues:
- Whether the CA erred in giving due course to a petition for annulment of judgment under Rule 47 as an extraordinary remedy.
- Whether Ciudadano’s petition constituted a collateral attack on Chico’s Torrens title.
- Whether the CA correctly found extrinsic fraud and lack of jurisdiction in the RTC’s decisions granting cancellation and issuance of a new title.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)